WEBVTT 

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>> Good afternoon. I'm Kristyn Pompa
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Guth with PT, today's webinar is on
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CTPAT Forced Labor. You'll be on mute
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during the presentation, we ask you
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submit questions you have in the CHAT
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feature. I'd like to pass it over to
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Felicia Pullam.>>
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All right. My name is Felicia Pullam.
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I'm the executive director of trade
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relations at CTP.>>
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In December, January to be national
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human trafficking prevention week. This
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is our second, national human traffic
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prevention. And a lot has happened
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since the first one.This
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is a priority issue for the bide Anne
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administration for DHS and for CTP.
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Almost 28 women, men and children are
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forced globally. The [Background
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Noise].Went
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into effect of June 2022. CTP has been
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working very hard for implementation
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law. Forced Labor is a major challenge
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for all of us. And we understand that
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many companies and many other
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organizations are working very hard on
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this area. We understand that-- thank
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you. For everybody who showed up today.
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Thank you for sharing your time with
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us. Thank you for your effort on Forced
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Labor and thank you for your interest in
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CTPAT which is a very important program
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that makes our country safer.So
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we are really glad that so many people
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are here today. And we will share
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information that's useful and enables
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you to get more involved.If
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you want to learn more of DHS's
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campaign, you can check out DHS.gov/--
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type in campaign--You
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can also visit CTP website. We hope to
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see you at the 2023 summit, scheduled
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for April 17 through 19 in Boston. So
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keep a look out for more information
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coming out on that, soon. I'd like to
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internal it over to our CTPAT Director,
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Manuel Garza.>>
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All right. Thank you so much for that,
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and Kris Krys from OTR helping us out on
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this wonderful webinar today.I
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know there was a little bit of audio
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with XD but can everybody hear mine
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okay? All right. I'm seeing much
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better. All right. Thank you very
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much.So
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Forced Labor is a big topic. You heard
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yesterday from the office of trade and
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the Forced Labor force division. Today
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you'll here about CTPAT. We have two
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programs. We have our security program
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and trade compliance program.Security
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is what everybody is responsible for.
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That's in CTPAT. Compliance is only for
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our U.S. importers. So I want to make
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that clear as we talk about the
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requirements for the program as they
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revolve around Forced Labor that
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everybody understands there are two
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programs. Security is what everybody
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has to follow and trade compliance is
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for importers that are part of trade
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compliance.Next
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s slide, please.So
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for those of you, I know we have a
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little over 900 is the last count I saw
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participants in this presentation here.
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We have about 11,000 partners that are
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part of our CTPAT security program. And
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we have just a little under 300 in our
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trade compliance program. So quite a
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big difference between the two. And
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trade compliance is really considered a
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huge benefit for those, you know, 300
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plus companies that are part of
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it.Security,
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everybody knows that it's, is you know,
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not only do we focus on Forced Labor,
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but it encompasses everything from
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cybersecurity, agricultural security,
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seal security, human resources,
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container inspections. Where trade
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compliance is really-- goes in a
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different direction and focused on the
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company providing CBP information and
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monitoring their own compliance.
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That's really the big difference. On
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the security side, CTPAT goes out and
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does the validations on the trade
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compliance side, importers are
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responsible for conducting
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self-assessments.Next
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slide, please.So
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for those of you that participate in the
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summit over the summer of 2022 in
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Anaheim, you may have heard Carmen Perez
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and Amy talk about the mandatory Forced
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Labor requirements that we're coming to
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the CTPAT trade compliance program.So
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they became mandatory August 1. And
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I'll go into details on what those
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requirements are. But August 1, it
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became a mandatory for brand new
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applicants into trait compliance.
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Again, this is only for trade compliance
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partners. I'll talk security in a few
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minutes.New
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applicants, and this is brand new
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companies applying for new compliance
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within CTPAT must meet the requirements
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at time of application. That's a really
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big, important thing that we want to
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make sure that everybody understands is
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that, if you are a new company that is
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applying to the trade compliance program
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today, you must meet those
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requirements.If
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you are already an existing trade
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compliance partner, your requirements
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are not due until you have one year from
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August, 1, 2022. So August 1, 2023ment
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your program requirements are not
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required until your annual notification
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letter which is due after August 1,
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2023. I want to be clear that for new
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applicants, it's due now. For existing
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partners and trade compliance, you have
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until 2023, August 1, 2023 to have them
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implemented and available.Next
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slide, please.Yeah,
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you can go to the next slide. I just
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talked about that, I'm sorry.>>
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On the CT CT, on the security side,
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minimum security criteria 3.9 and can I
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apologize this slide is a little old. I
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should say it's 27 days old. But
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minimum security criteria 3.9 is CTPAT
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partners must, that should, is no longer
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there. It is now a must.So
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for those of you that are importers,
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those of you who are manufacturers and
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those of you who are exporters in the
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CTPAT program, the minimum security
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criteria, 3.9 has changed. And it is
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now CTPAT partners must have a
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documented social compliance, program in
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place. So we are going to publish that.
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It will be part of the, our updated
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booklets that we post. I don't know
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that we'll be able to change it in our
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CTPAT portal just yet. We're
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undergoing changes to the portal.And
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you know, so we're actually, we're
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developing a Newport al to they're
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really limiting the development pieces
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of the existing one. It will a part of
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the new, portal within the security
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profile of the new, portal. Again,
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criteria 3.9 for CTPAT partners must.
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So when we do share this, we will make
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sure that we get you an updated slide
00:10:07.778 --> 00:10:09.829
for this one because it is a must. And
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I don't want to cause any confusion out
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there.Next
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slide, please.*.
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So what are the Forced Labor
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requirements? We have six new Forced
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Labor requirements that the CTPAT
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program worked in conjunction with the
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Advisory Committee for the last, I would
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say three and a half to four years.
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We've been working diligently on what
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these Forced Labor requirements would
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look like. And these are the six.
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We're looking at risk based business
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mapping. Something that companies
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already do today. You're already
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mapping at your business partners and
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you're identifying risk. Code of
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conduct, that is something that-- code
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of conduct specifically on Forced Labor,
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social compliance.We'll
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be looking at evidence of
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implementation. We'll be looking at
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due diligence and training. We're
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going to require a remediation plan,
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that you have something in place so
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that, when a business entity of yours or
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a business partner of yours is
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identified to be sourcing from, with
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Forced Labor or has forced labor in one
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of their facilities, what are you going
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to do about it? That's our remediation
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plan.And
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finally we're going to ask that you
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share best practices as a business
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partner. Best practices must be, they
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need to be something that we can share,
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right? Things that we want to make sure
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that the rest of the trade in
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understand, hey, this is what business
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partner is doing, or this is how they're
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making this work. Or these are some of
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the things that they're using to elevate
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their practice to the next level so that
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it helps and keeps forced labor out of
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their particular supply chain.Next
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slide, please.So
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risk based mapping. Partners are
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required to conduct risk based mapping
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of their businesses. Companies should
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determine within their organization what
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imports are considered high risk. For
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those of you on the security side, I
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know we've gone through this many times,
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me as a supply chain specialist in years
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past. Companies would always ask me,
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Manuel, what constitutes high risk
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andAnd
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we said it then, I'll say it faux, high
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risk is for you as a company to decide
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and determine what is high risk.
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Because high risk for you may mean
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something completely different for
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someone else. The idea is that you are
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looking at a risk within your business
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model. And that companies, you know,
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can understand.And
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so when CTPAT does the evaluation, we
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can say, okay, you do have a risk
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process in place. And a commitment
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should be made in include in the code of
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conduct. And CBP will likely be asking
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for evidence of your supply chain
00:13:36.968 --> 00:13:40.741
mapping. So things that you guys all do
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today for trade compliance, when the
00:13:43.262 --> 00:13:45.019
national account manager is doing the
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report and reviewing all the
00:13:46.794 --> 00:13:48.603
documentation, this is something that
00:13:48.603 --> 00:13:51.061
they'll be looking for.Again,
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current business-- current applicants
00:13:54.564 --> 00:13:58.962
will have to have this in place. And 16
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partners will have to make sure that
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this is available after August 1,
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2023.Next
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slide.Code
00:14:15.396 --> 00:14:19.646
of conduct. Partners must create a code
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of conduct statement that represents
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their position against the use of forced
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labor within any part of their supply
00:14:26.936 --> 00:14:28.004
chain.So
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when we were putting this together, we
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talked to a number of companies that
00:14:32.027 --> 00:14:38.176
were in the code act. Almost everybody
00:14:38.176 --> 00:14:42.831
that that we speak to was in CTPAT. *
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and every single one of them already has
00:14:45.494 --> 00:14:48.407
some type of code of conduct that
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identifies the use of forced labor
00:14:51.718 --> 00:14:53.873
within their supply chain.So
00:14:53.873 --> 00:14:56.382
this one right here is probably one of
00:14:56.382 --> 00:14:59.557
the easiest requirements of the program.
00:14:59.557 --> 00:15:03.483
Most of you already have this listed on
00:15:03.483 --> 00:15:05.796
your websites. If you don't, we're not
00:15:05.796 --> 00:15:08.059
telling you how long it has to be, how
00:15:08.059 --> 00:15:10.443
short it has to be. As long as you are
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indicating that you, as a company, do
00:15:15.809 --> 00:15:20.208
not adhere to the use of forced labor
00:15:20.208 --> 00:15:22.205
within the supply chain, that you are
00:15:22.205 --> 00:15:26.512
not going to accept that.The
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code of conduct, the code of conduct
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statement must be uploaded to the portal
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and published by you, the partner for
00:15:34.960 --> 00:15:37.020
the program.Next
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slide, please.So
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if you're in the CTPAT program already,
00:15:49.497 --> 00:15:51.935
there's no reason you shouldn't be aware
00:15:51.935 --> 00:15:54.400
of this. But evidence of
00:15:54.400 --> 00:15:56.802
implementation, that has already been a
00:15:56.802 --> 00:15:58.464
requirement, you know, for a number of
00:15:58.464 --> 00:16:01.764
years in regards to the minimum security
00:16:01.764 --> 00:16:04.259
criteriamentS
00:16:04.259 --> 00:16:06.123
as we go out and collect the
00:16:06.123 --> 00:16:08.848
validations, we tell you, you need to
00:16:08.848 --> 00:16:11.094
show us how you implemented that policy.
00:16:11.094 --> 00:16:13.938
There's nothing different about it on
00:16:13.938 --> 00:16:15.476
trade compliance. It's the same thing.
00:16:15.476 --> 00:16:17.804
You're going to have to show us
00:16:17.804 --> 00:16:20.223
evidence of implementation of your
00:16:20.223 --> 00:16:22.987
social compliance program. Right?So
00:16:22.987 --> 00:16:26.483
there should be-- that should not come
00:16:26.483 --> 00:16:29.470
as a shock to anybody. Evidence can be
00:16:29.470 --> 00:16:32.767
videos. It can be training information.
00:16:32.767 --> 00:16:37.254
It can be tests that you guys conduct.
00:16:37.254 --> 00:16:40.577
Any audits that you all conduct, et
00:16:40.577 --> 00:16:42.715
cetera, et cetera.You
00:16:42.715 --> 00:16:46.585
know, examples of evidence may include
00:16:46.585 --> 00:16:48.987
unredacted audits, training, et
00:16:48.987 --> 00:16:50.137
cetera.Next
00:16:50.137 --> 00:16:58.815
slide, please.And
00:16:58.815 --> 00:17:00.687
like I mentioned before, training, you
00:17:00.687 --> 00:17:04.634
know, that is also of utmost important.
00:17:04.634 --> 00:17:08.553
It's most importantly-- it's most
00:17:08.553 --> 00:17:10.331
important so your business partners
00:17:10.331 --> 00:17:13.054
understand this as well. And that they
00:17:13.054 --> 00:17:16.475
should be conducting their own training,
00:17:16.475 --> 00:17:18.687
you know, to make sure that this is not
00:17:18.687 --> 00:17:21.869
happening. And it's not -- it doesn't
00:17:21.869 --> 00:17:24.772
have to be 100% of the employees need to
00:17:24.772 --> 00:17:27.173
be trained on this. Again, this is all
00:17:27.173 --> 00:17:28.958
part of your risk. You identify where
00:17:28.958 --> 00:17:30.825
the risk is. You identify who needs to
00:17:30.825 --> 00:17:33.478
be trained within the program, the
00:17:33.478 --> 00:17:38.194
people that are handling the HR side of
00:17:38.194 --> 00:17:40.635
it, maybe the people actually doing the
00:17:40.635 --> 00:17:43.529
work, the job of building the widgets,
00:17:43.529 --> 00:17:45.305
whatever it is that they're making in
00:17:45.305 --> 00:17:48.079
the factories. Those are the people you
00:17:48.079 --> 00:17:50.294
need to get the information out to
00:17:50.294 --> 00:17:52.359
them.And
00:17:52.359 --> 00:17:56.318
of course, the last bullet there says
00:17:56.318 --> 00:17:59.264
that suppliers' business model and code
00:17:59.264 --> 00:18:00.916
of conduct states that they will not
00:18:00.916 --> 00:18:03.273
partner with any businesses that use
00:18:03.273 --> 00:18:05.610
forced labor. It's important. Right?
00:18:05.610 --> 00:18:07.884
It's not just for each of you. It's for
00:18:07.884 --> 00:18:10.219
your business partners as well to say,
00:18:10.219 --> 00:18:12.189
hey, we're not going to accept, we're
00:18:12.189 --> 00:18:14.278
not going to stand for forced labor
00:18:14.278 --> 00:18:18.302
within our supply chain.Next
00:18:18.302 --> 00:18:21.359
slide, please.So
00:18:21.359 --> 00:18:23.760
I mentioned earlier, the remediation
00:18:23.760 --> 00:18:26.104
plan, partners must maintain a
00:18:26.104 --> 00:18:28.408
remediation plan for their organization
00:18:28.408 --> 00:18:31.033
in the event that forced labor is
00:18:31.033 --> 00:18:33.570
identified in their supply chains. Part
00:18:33.570 --> 00:18:36.117
of the plan must include the process for
00:18:36.117 --> 00:18:40.801
disclosing the identification to CBP and
00:18:40.801 --> 00:18:42.453
outlining the necessary steps for the
00:18:42.453 --> 00:18:45.173
organization's employees and suppliers
00:18:45.173 --> 00:18:47.378
to undertake and correct the issue.I
00:18:47.378 --> 00:18:49.000
will tell you that, and we're going to
00:18:49.000 --> 00:18:51.438
get to benefits. Everybody's going,
00:18:51.438 --> 00:18:54.057
what's in it for me? We'll talk about
00:18:54.057 --> 00:18:56.928
benefits in a few minutes here. But I
00:18:56.928 --> 00:18:59.357
want you to understand that a this is
00:18:59.357 --> 00:19:00.806
extremely important that you have a plan
00:19:00.806 --> 00:19:05.293
in place that you notify CBP whether
00:19:05.293 --> 00:19:07.319
you're notifying your national account
00:19:07.319 --> 00:19:10.600
manager for trade compliance partners.
00:19:10.600 --> 00:19:14.213
You're notifying, compliance email box.
00:19:14.213 --> 00:19:16.214
You're notifying the Forced Labor email
00:19:16.214 --> 00:19:20.265
box. There's lots of companies that you
00:19:20.265 --> 00:19:23.926
can, there are lots of resources, I'm
00:19:23.926 --> 00:19:29.380
sorry, that you can reach out to within
00:19:29.380 --> 00:19:35.195
CBP please keep that as part of your
00:19:35.195 --> 00:19:38.266
note know remediation plan so there are
00:19:38.266 --> 00:19:39.708
no issues.We
00:19:39.708 --> 00:19:41.668
understand this. This is a big issue.
00:19:41.668 --> 00:19:43.759
We've talked about it with senior
00:19:43.759 --> 00:19:48.372
leadership within CBP with nor he is
00:19:48.372 --> 00:19:51.343
over the phone and the office of trade
00:19:51.343 --> 00:19:54.631
and even our acting commissioner Troy
00:19:54.631 --> 00:19:58.900
Miller is familiar with the desire for
00:19:58.900 --> 00:20:01.016
companies to want to provide information
00:20:01.016 --> 00:20:03.426
but at the same time, you know, not get
00:20:03.426 --> 00:20:04.974
in trouble for providing that
00:20:04.974 --> 00:20:06.475
information.So
00:20:06.475 --> 00:20:10.838
we are working very hard at trying to
00:20:10.838 --> 00:20:16.425
identify some way that partners in
00:20:16.425 --> 00:20:21.406
CTPAT, trade compliance, CTPAT security
00:20:21.406 --> 00:20:32.649
can provide information to CBP without
00:20:32.649 --> 00:20:35.395
penalty at thises or having shipment
00:20:35.395 --> 00:20:37.395
stopped and things like that. * it's
00:20:37.395 --> 00:20:40.819
not a prior disclosure because that's
00:20:40.819 --> 00:20:42.483
very specific. But we're trying to
00:20:42.483 --> 00:20:44.133
identify something similar to that so
00:20:44.133 --> 00:20:47.957
partners are not worried about
00:20:47.957 --> 00:20:50.043
disclosing that information.Next
00:20:50.043 --> 00:20:57.064
slide, please.And
00:20:57.064 --> 00:21:01.344
best practices and path forward. The
00:21:01.344 --> 00:21:04.874
key thing to making, not making sure,
00:21:04.874 --> 00:21:10.665
but to help others have good strategies,
00:21:10.665 --> 00:21:13.757
a good way to do things is by sharing
00:21:13.757 --> 00:21:16.315
best practices. Sharing best practices
00:21:16.315 --> 00:21:18.288
with not only your national account
00:21:18.288 --> 00:21:21.119
manager or your supply chain security
00:21:21.119 --> 00:21:27.613
specialists, to me, to many Carmen, to *
00:21:27.613 --> 00:21:30.483
the oughts of trade, Forced Labor
00:21:30.483 --> 00:21:32.448
division. When it comes to forced
00:21:32.448 --> 00:21:34.563
labor, Nick you think as a business
00:21:34.563 --> 00:21:36.500
partner you think is doing great, we
00:21:36.500 --> 00:21:38.529
want to make sure that we can get that
00:21:38.529 --> 00:21:42.119
information * out to the public so that
00:21:42.119 --> 00:21:45.613
they can implement potentially similar
00:21:45.613 --> 00:21:46.901
processes.You
00:21:46.901 --> 00:21:49.612
know, it's not just about one company
00:21:49.612 --> 00:21:51.833
doing great. It's about all of us
00:21:51.833 --> 00:21:55.219
trying to do as much as we can to
00:21:55.219 --> 00:21:57.773
eradicate forced labor from the supply
00:21:57.773 --> 00:21:59.703
chain.Next
00:21:59.703 --> 00:22:04.336
slide, please.And
00:22:04.336 --> 00:22:06.708
so I mentioned that there were some
00:22:06.708 --> 00:22:11.319
benefits to this program. And we have
00:22:11.319 --> 00:22:14.599
identified three that he have with
00:22:14.599 --> 00:22:16.720
already established. And we have
00:22:16.720 --> 00:22:21.153
already provided to the trade.So
00:22:21.153 --> 00:22:25.186
November of last year, November, 2022,
00:22:25.186 --> 00:22:30.022
you know, we published a document with
00:22:30.022 --> 00:22:33.117
the new benefits for trade compliance
00:22:33.117 --> 00:22:36.641
partners, specifically this is for trade
00:22:36.641 --> 00:22:40.055
compliance partners. And the first one
00:22:40.055 --> 00:22:43.851
is pridization review of admissibility
00:22:43.851 --> 00:22:46.375
packages submitted for forced labor
00:22:46.375 --> 00:22:47.965
deexpr its.So
00:22:47.965 --> 00:22:51.364
companies that are submitting their
00:22:51.364 --> 00:22:54.923
documents to the ports * and to the
00:22:54.923 --> 00:22:58.146
centers are having theirs moved up to
00:22:58.146 --> 00:23:02.566
the front of the line for review. So
00:23:02.566 --> 00:23:05.944
that's a-- I mean, that's not an easy
00:23:05.944 --> 00:23:08.595
lift because these packages are no way
00:23:08.595 --> 00:23:11.124
easy reviews. But it definitely does
00:23:11.124 --> 00:23:15.427
help you as a CTPAT compliance partner
00:23:15.427 --> 00:23:19.295
to get your shipment closer to seether
00:23:19.295 --> 00:23:23.451
being released or having a * decision
00:23:23.451 --> 00:23:27.000
made instead of I waiting pour however
00:23:27.000 --> 00:23:28.442
Hong period of time you have to wait
00:23:28.442 --> 00:23:31.122
for, two months, three months. It can
00:23:31.122 --> 00:23:35.610
take a while for the admissibility
00:23:35.610 --> 00:23:42.267
completion.Redelivery
00:23:42.267 --> 00:23:45.224
holds. So what we identified with this
00:23:45.224 --> 00:23:49.894
was that CTPAT trade compliance partners
00:23:49.894 --> 00:23:53.247
have had shipments arrive at their
00:23:53.247 --> 00:23:56.680
facility. And we will allow those
00:23:56.680 --> 00:23:58.797
shipments to be, if they're already
00:23:58.797 --> 00:24:00.759
there at your facility and then we
00:24:00.759 --> 00:24:02.100
identify that there's an issue with
00:24:02.100 --> 00:24:05.846
them, we will allow them to stay intact
00:24:05.846 --> 00:24:09.309
at the facility.So
00:24:09.309 --> 00:24:12.709
this is a benefit so that you're not
00:24:12.709 --> 00:24:15.742
having to redeliver the goods for
00:24:15.742 --> 00:24:19.263
physical inspection. Okay? Until the
00:24:19.263 --> 00:24:22.225
admissibility determination is made.
00:24:22.225 --> 00:24:24.953
So, you know, it helps especially if
00:24:24.953 --> 00:24:29.230
there's no physical inspection that's
00:24:29.230 --> 00:24:32.661
required and admissibility determination
00:24:32.661 --> 00:24:35.533
is made that it can stay in the U.S. So
00:24:35.533 --> 00:24:39.063
really strong benefit for partners.Next
00:24:39.063 --> 00:24:44.641
slide, please.And
00:24:44.641 --> 00:24:48.048
for shipments that are detained at the
00:24:48.048 --> 00:24:52.096
border, subject of a WRO, we are
00:24:52.096 --> 00:24:55.381
allowing shipments to move to bonded
00:24:55.381 --> 00:24:57.246
facilities. So straight compliance
00:24:57.246 --> 00:24:59.896
partners who have shipments detained due
00:24:59.896 --> 00:25:02.654
to the WROs will be allowed to move
00:25:02.654 --> 00:25:06.391
them to the bonded facility held intact
00:25:06.391 --> 00:25:10.256
in the a an as missability determination
00:25:10.256 --> 00:25:13.511
is made by CBP.Again,
00:25:13.511 --> 00:25:16.903
your detention gets to go to a bonded
00:25:16.903 --> 00:25:18.431
facility. Your shipment is going to be
00:25:18.431 --> 00:25:21.959
able to get expedite the review for
00:25:21.959 --> 00:25:24.359
admissibility claims and move a lot
00:25:24.359 --> 00:25:27.797
faster. So that's what we have in store
00:25:27.797 --> 00:25:32.192
for CTPAT trade compliance.Next
00:25:32.192 --> 00:25:35.156
slide, please.I
00:25:35.156 --> 00:25:39.057
think that's the slides.So
00:25:39.057 --> 00:25:40.925
I know we've got a lot of questions that
00:25:40.925 --> 00:25:43.238
have been coming in. And I've got my
00:25:43.238 --> 00:25:45.033
team who is going to present any
00:25:45.033 --> 00:25:49.729
questions to me. Carmen, did I miss
00:25:49.729 --> 00:25:51.045
anything before we get into the
00:25:51.045 --> 00:25:51.882
questions?>>
00:25:51.882 --> 00:25:54.284
Carmen: No, sirment I couldn't have
00:25:54.284 --> 00:25:56.251
done it better myself.>>
00:25:56.251 --> 00:25:58.089
*>>
00:25:58.089 --> 00:26:00.711
Manuel Garza: Thank you. So we'll turn
00:26:00.711 --> 00:26:07.602
it over to the questions.>>
00:26:07.602 --> 00:26:18.636
The first one-- okay. I think one--
00:26:18.636 --> 00:26:22.036
it's not a question. But Teresa is
00:26:22.036 --> 00:26:25.873
joining at 2:45 to answer any specific
00:26:25.873 --> 00:26:27.433
Forced Labor questions. The first
00:26:27.433 --> 00:26:30.060
question is, at what pointed is the
00:26:30.060 --> 00:26:33.360
zip-- required at entry, crossing or
00:26:33.360 --> 00:26:36.297
transmission? In the entry summary?>>
00:26:36.297 --> 00:26:39.693
Manuel Garza: I don't have that answer.
00:26:39.693 --> 00:26:42.116
We can get back.>>
00:26:42.116 --> 00:26:47.156
Okay. Do you want to do the last one or
00:26:47.156 --> 00:26:51.150
continue?>>
00:26:51.150 --> 00:26:54.894
My apologies. I didn't hit the unmute
00:26:54.894 --> 00:26:56.297
button quick enough. We have another
00:26:56.297 --> 00:27:00.019
question that just came in. Is there a
00:27:00.019 --> 00:27:02.361
cost to become a CTPAT member?>>
00:27:02.361 --> 00:27:04.996
Manuel Garza: Is there a cost? Well,
00:27:04.996 --> 00:27:08.306
there's no fee. The CTPAT program does
00:27:08.306 --> 00:27:10.925
not charge a fee for the program.
00:27:10.925 --> 00:27:14.983
Either security or trade compliance,
00:27:14.983 --> 00:27:18.076
there are class associated with
00:27:18.076 --> 00:27:22.874
developing your CTPAT program especially
00:27:22.874 --> 00:27:25.314
if you don't have policies in place
00:27:25.314 --> 00:27:30.341
already. So you would need time to
00:27:30.341 --> 00:27:34.730
develop policies and procedures.You
00:27:34.730 --> 00:27:37.010
have to look at all the eligibility
00:27:37.010 --> 00:27:38.911
requirements. You have to look at all
00:27:38.911 --> 00:27:40.801
the minimum security criteria. You can
00:27:40.801 --> 00:27:43.888
do all of that prior to applying to the
00:27:43.888 --> 00:27:47.176
program. You know, there's a lot of
00:27:47.176 --> 00:27:49.820
physical security components that are
00:27:49.820 --> 00:27:51.914
required. So you may have to take a
00:27:51.914 --> 00:27:54.346
look at your facility, and is it
00:27:54.346 --> 00:27:57.990
properly securitied? Do you have doors
00:27:57.990 --> 00:28:00.550
that are locked? Do you have lights and
00:28:00.550 --> 00:28:03.389
cameras? Do you employee employ
00:28:03.389 --> 00:28:06.571
security guards? * there's a lot of *
00:28:06.571 --> 00:28:08.661
things that you have to do before.I
00:28:08.661 --> 00:28:11.286
think everybody on the line that is
00:28:11.286 --> 00:28:13.466
CTPAT partner can tell you, there's no
00:28:13.466 --> 00:28:16.339
fee. There definitely is a cost to
00:28:16.339 --> 00:28:19.860
participating in the program.
00:28:19.860 --> 00:28:21.695
thank you for that Kate.>>
00:28:21.695 --> 00:28:25.543
Thank you, sir. I'll just jump in with
00:28:25.543 --> 00:28:27.024
another one. We've been seeing a few
00:28:27.024 --> 00:28:29.225
questions regarding some of the dates
00:28:29.225 --> 00:28:31.234
for implementation. So maybe could we
00:28:31.234 --> 00:28:34.298
clarify that a little bit specifically
00:28:34.298 --> 00:28:37.697
there's been questions regarding the
00:28:37.697 --> 00:28:41.654
portal change after 8-1, 23. And how
00:28:41.654 --> 00:28:44.182
the forces labor * requirements will be
00:28:44.182 --> 00:28:46.994
included in the annual reporting.>>
00:28:46.994 --> 00:28:52.677
Manuel Garza: Okay, so August 1, 2022,
00:28:52.677 --> 00:28:57.201
new companies that are applying to trade
00:28:57.201 --> 00:29:02.140
compliance must * provide their
00:29:02.140 --> 00:29:04.630
information on the six items, the six
00:29:04.630 --> 00:29:07.926
requirements for Forced Labor for trade
00:29:07.926 --> 00:29:09.210
compliance.So
00:29:09.210 --> 00:29:12.921
brand new companies applying after
00:29:12.921 --> 00:29:15.819
August 1, 2022 must provide that
00:29:15.819 --> 00:29:17.786
information at the time of application.
00:29:17.786 --> 00:29:23.033
The existing partners are not required
00:29:23.033 --> 00:29:27.870
to provide that information until their
00:29:27.870 --> 00:29:31.475
annual notification letter that is due
00:29:31.475 --> 00:29:37.644
after August 1, 2023.CTPAT
00:29:37.644 --> 00:29:42.112
security partners mandatory requirement
00:29:42.112 --> 00:29:44.979
went into effect for companies that must
00:29:44.979 --> 00:29:47.851
have a social compliance program in
00:29:47.851 --> 00:29:52.655
place went into effect January 1, 2023.
00:29:52.655 --> 00:29:56.428
Again, that a loo iz to importers,
00:29:56.428 --> 00:30:00.925
manufacturers, * and exporters of the
00:30:00.925 --> 00:30:04.138
program.>>The
00:30:04.138 --> 00:30:08.301
CTPAT portal. Let me clarify that. On
00:30:08.301 --> 00:30:12.231
the security side, the security profile
00:30:12.231 --> 00:30:18.606
of a partner will only, will still say a
00:30:18.606 --> 00:30:26.902
"should." It will not change until the
00:30:26.902 --> 00:30:28.852
Newport al is released in June of this
00:30:28.852 --> 00:30:30.160
year.Once
00:30:30.160 --> 00:30:32.873
the Newport al is released and the new
00:30:32.873 --> 00:30:36.963
security profile * is updated, partners
00:30:36.963 --> 00:30:39.373
will have to make those changes in the
00:30:39.373 --> 00:30:43.016
security profile. That does not exempt
00:30:43.016 --> 00:30:46.317
you, if you have a validation that's due
00:30:46.317 --> 00:30:48.719
in March or if we do a validation in
00:30:48.719 --> 00:30:55.519
March of this year, that does not exempt
00:30:55.519 --> 00:30:58.306
you from not having the policies in
00:30:58.306 --> 00:30:59.238
place.If
00:30:59.238 --> 00:31:01.649
you're a brand new partner applying to
00:31:01.649 --> 00:31:05.071
the CTPAT trade compliance program, as
00:31:05.071 --> 00:31:10.560
of August 1, 2022 you must include those
00:31:10.560 --> 00:31:12.777
six requirements into your
00:31:12.777 --> 00:31:15.802
application.If
00:31:15.802 --> 00:31:18.330
you are an existing trade compliance
00:31:18.330 --> 00:31:23.041
partner, you have to submit requirements
00:31:23.041 --> 00:31:26.041
with why you are annual notification
00:31:26.041 --> 00:31:31.219
letter package that is due after August
00:31:31.219 --> 00:31:34.125
1, 2023.So
00:31:34.125 --> 00:31:37.491
if your A and L is due in February of 23
00:31:37.491 --> 00:31:40.389
if, you don't have to include the
00:31:40.389 --> 00:31:45.043
information on Forced Labor. If you're
00:31:45.043 --> 00:31:51.078
ANL is due in November * of 2023, then
00:31:51.078 --> 00:31:55.107
yes, you must include your-- the Forced
00:31:55.107 --> 00:32:00.161
Labor requirements within that AN. L.
00:32:00.161 --> 00:32:03.838
And on the security side, * validations
00:32:03.838 --> 00:32:08.568
taking place in 2023, they'll be looking
00:32:08.568 --> 00:32:10.037
to make sure that companies have
00:32:10.037 --> 00:32:14.185
implemented the Forced Labor
00:32:14.185 --> 00:32:21.307
requirements for importers, exporters,
00:32:21.307 --> 00:32:23.279
and for manufacturers.Ing
00:32:23.279 --> 00:32:26.460
again, * it won't be available in the
00:32:26.460 --> 00:32:35.107
security profile module in the portal in
00:32:35.107 --> 00:32:38.163
had mid to late June of this year.Next
00:32:38.163 --> 00:32:38.791
question.>>
00:32:38.791 --> 00:32:40.967
Will the slides be available on the
00:32:40.967 --> 00:32:43.060
CTPAT website?>>
00:32:43.060 --> 00:32:46.767
Manuel Garza: Yes, ma'am, they will.>>
00:32:46.767 --> 00:32:53.105
Okay. Let's see. Another question. Can
00:32:53.105 --> 00:32:55.986
you expound on the confidentiality
00:32:55.986 --> 00:32:58.599
regarding the remediation plan?>>
00:32:58.599 --> 00:33:02.335
Manuel Garza: Um, confidentiality, in
00:33:02.335 --> 00:33:04.867
terms of remediation, if you were to
00:33:04.867 --> 00:33:11.672
notify the CBP, anybody within CBP with
00:33:11.672 --> 00:33:15.520
potential, if you identified a forced
00:33:15.520 --> 00:33:17.631
labor within your supply chain, we
00:33:17.631 --> 00:33:20.591
don't have a benefit in place for that
00:33:20.591 --> 00:33:22.244
yet. We are working to develop
00:33:22.244 --> 00:33:23.992
something.And
00:33:23.992 --> 00:33:26.277
as soon as we get it developed, we're
00:33:26.277 --> 00:33:29.407
working with the office of trade. We're
00:33:29.407 --> 00:33:31.263
working with the office of chief
00:33:31.263 --> 00:33:34.445
counsel. And as senior leadership has
00:33:34.445 --> 00:33:37.407
expressed an interest in us providing
00:33:37.407 --> 00:33:39.832
some type of benefit for the partners
00:33:39.832 --> 00:33:43.804
that provide information to CBP about
00:33:43.804 --> 00:33:46.419
forced labor within the supply chain.>>
00:33:46.419 --> 00:33:52.684
One other one, is the program open to
00:33:52.684 --> 00:33:54.084
new applicants?>>
00:33:54.084 --> 00:33:59.466
Manuel Garza yes, ma'am, as of August 1,
00:33:59.466 --> 00:34:03.004
2022, the trade compliance * program has
00:34:03.004 --> 00:34:07.971
opened for new importer applicants. And
00:34:07.971 --> 00:34:11.501
the CTPAT security program has been-- is
00:34:11.501 --> 00:34:13.424
currently available for new applicants
00:34:13.424 --> 00:34:15.325
as well.>>
00:34:15.325 --> 00:34:17.831
Okay, here's another one that came in.
00:34:17.831 --> 00:34:20.798
Can you please qualify whether movement
00:34:20.798 --> 00:34:24.990
of goods bonded facility is permitted
00:34:24.990 --> 00:34:29.102
willful deexpr its or WRO detentions?
00:34:29.102 --> 00:34:33.619
If it's just permitted for WRO, can you
00:34:33.619 --> 00:34:36.329
advise what are the other benefits are
00:34:36.329 --> 00:34:40.545
for CTPAT trade compliance. Prioritized
00:34:40.545 --> 00:34:42.858
review or redelivery hold are also
00:34:42.858 --> 00:34:45.229
limited to WRO?>>
00:34:45.229 --> 00:34:48.785
Manuel Garza: Um, it's a complicated
00:34:48.785 --> 00:34:53.493
answer. We'll provide a more feedback
00:34:53.493 --> 00:34:56.020
later.>>
00:34:56.020 --> 00:34:59.422
Thank you. We did get a question
00:34:59.422 --> 00:35:03.289
regarding benefits and the question is:
00:35:03.289 --> 00:35:05.721
Would one be kicked out of CTPAT if they
00:35:05.721 --> 00:35:08.034
did not report any Forced Labor found?>>
00:35:08.034 --> 00:35:09.526

00:35:09.526 --> 00:35:12.880
* can you repeat the question?>>
00:35:12.880 --> 00:35:15.924
The question is, would one be kicked out
00:35:15.924 --> 00:35:18.480
of CTPAT if they did not report any
00:35:18.480 --> 00:35:20.952
forced labor that was found?>>
00:35:20.952 --> 00:35:24.067
Manuel Garza: Would you be kicked out?
00:35:24.067 --> 00:35:27.043
So if forced labor is identified within
00:35:27.043 --> 00:35:29.016
your supply chain, and you knew about it
00:35:29.016 --> 00:35:32.673
and you didn't notify us, would you be
00:35:32.673 --> 00:35:37.127
kicked out?It's
00:35:37.127 --> 00:35:39.747
too general of a statement. I think
00:35:39.747 --> 00:35:42.930
we'd have to look at all the
00:35:42.930 --> 00:35:45.584
circumstances just as we do with our
00:35:45.584 --> 00:35:49.226
current removal process for security and
00:35:49.226 --> 00:35:52.012
for trade compliance.But
00:35:52.012 --> 00:35:54.539
in a nutshell, I don't think you will be
00:35:54.539 --> 00:35:57.845
kicked out for not reporting. But if
00:35:57.845 --> 00:36:02.029
you do know, it would behoove you to
00:36:02.029 --> 00:36:05.647
make us aware of a forced labor issue
00:36:05.647 --> 00:36:07.893
and that you're addressing it.The
00:36:07.893 --> 00:36:09.760
idea is that, we want good business
00:36:09.760 --> 00:36:12.824
partners. And you're a good business
00:36:12.824 --> 00:36:17.034
partner, you're going to gain a lot more
00:36:17.034 --> 00:36:20.220
respect from CBP by informing us of some
00:36:20.220 --> 00:36:22.652
of the concerns or some of the issues
00:36:22.652 --> 00:36:27.458
you've seen or identified. And we can
00:36:27.458 --> 00:36:34.869
work with you.The
00:36:34.869 --> 00:36:39.385
example I'll use is trucks carrying
00:36:39.385 --> 00:36:42.815
drugs across the border. If the
00:36:42.815 --> 00:36:45.319
business partner is notifying us that,
00:36:45.319 --> 00:36:50.156
hey, my truck driver went off route
00:36:50.156 --> 00:36:52.902
didn't go the way he was supposed to.
00:36:52.902 --> 00:36:55.802
He's not responding to my phone calls,
00:36:55.802 --> 00:36:58.342
please inspect him. And we inspect him
00:36:58.342 --> 00:37:01.041
and we find drugs.The
00:37:01.041 --> 00:37:04.095
likelihood of getting suspended is very
00:37:04.095 --> 00:37:05.906
low. You're telling us because you
00:37:05.906 --> 00:37:07.812
identify it as part of your risk
00:37:07.812 --> 00:37:10.152
assessment and your monitoring services
00:37:10.152 --> 00:37:12.346
that there was an issue. And it worked.
00:37:12.346 --> 00:37:16.608
And it paid off.It
00:37:16.608 --> 00:37:19.337
the driver shows up and says, hey, I got
00:37:19.337 --> 00:37:22.976
pulled over on the side of the road, I
00:37:22.976 --> 00:37:24.749
don't know what they did to the back of
00:37:24.749 --> 00:37:27.622
the truck. Make sure you send me to
00:37:27.622 --> 00:37:29.406
examination for inspection. We're
00:37:29.406 --> 00:37:30.683
probably not going to do anything.
00:37:30.683 --> 00:37:33.774
We're probably going to, you know, be
00:37:33.774 --> 00:37:35.177
very grateful.We'll
00:37:35.177 --> 00:37:36.921
do an investigation just to see what
00:37:36.921 --> 00:37:40.976
could we as a program do to help? What
00:37:40.976 --> 00:37:46.341
can the company do to put themselves in
00:37:46.341 --> 00:37:48.427
a better posture. But you're telling
00:37:48.427 --> 00:37:49.741
us. You're providing that
00:37:49.741 --> 00:37:51.743
information.And
00:37:51.743 --> 00:37:57.207
so we want to be able to do that with
00:37:57.207 --> 00:37:58.983
forced labor. We want to be able to
00:37:58.983 --> 00:38:00.765
tell you, thank you for telling us about
00:38:00.765 --> 00:38:05.516
it. Now, let's move forward. and get
00:38:05.516 --> 00:38:08.308
there.>>
00:38:08.308 --> 00:38:10.620
Next question?>>
00:38:10.620 --> 00:38:14.330
About the security profile. Should it be
00:38:14.330 --> 00:38:18.733
updated by the anniversary or by June
00:38:18.733 --> 00:38:19.237
2023?>>
00:38:19.237 --> 00:38:21.880
Manuel Garza: So we'll send out
00:38:21.880 --> 00:38:24.190
notifications of what needs to be done
00:38:24.190 --> 00:38:28.165
with the peoplation of the new, portal
00:38:28.165 --> 00:38:33.082
as we get closer. Implementation *>>
00:38:33.082 --> 00:38:36.793
Okay.There's
00:38:36.793 --> 00:38:40.958
some that I think would be best if-- was
00:38:40.958 --> 00:38:42.711
going to join because they're
00:38:42.711 --> 00:38:45.888
specifically on the way of Forced Labor
00:38:45.888 --> 00:38:49.822
prevention act. Here's one.Director
00:38:49.822 --> 00:38:53.224
Garza on the webinar yesterday they
00:38:53.224 --> 00:38:55.965
advise all shipments detain can be moved
00:38:55.965 --> 00:39:00.683
to a bonded warehouse, can you reconfirm
00:39:00.683 --> 00:39:02.895
this. As you discussed today your
00:39:02.895 --> 00:39:06.139
November 2022 letter advised the CTPAT
00:39:06.139 --> 00:39:08.209
compliance program benefit was having
00:39:08.209 --> 00:39:12.599
the ability to move goods detained based
00:39:12.599 --> 00:39:15.814
on a-- is this benefit open to all?>>
00:39:15.814 --> 00:39:18.535
Manuel Garza: Like I said earlier, it
00:39:18.535 --> 00:39:22.269
really is for the WROs at this point.
00:39:22.269 --> 00:39:25.282
We are still evaluating where we should
00:39:25.282 --> 00:39:29.536
open it up to all or not.>>
00:39:29.536 --> 00:39:34.312
And this question, I can answer. Do
00:39:34.312 --> 00:39:36.593
tier three existing partners
00:39:36.593 --> 00:39:39.120
automatically become trait compliance
00:39:39.120 --> 00:39:40.868
partner?No,
00:39:40.868 --> 00:39:42.624
not automatically. You have to apply to
00:39:42.624 --> 00:39:44.075
the program. Correct?>>
00:39:44.075 --> 00:39:48.418
Manuel Garza: Correct.>>
00:39:48.418 --> 00:39:58.276
I don't see another-- oh, here. Most
00:39:58.276 --> 00:40:00.717
exciting CTPAT have evidence of full
00:40:00.717 --> 00:40:03.453
implementation or just a good start
00:40:03.453 --> 00:40:07.202
especially if a large importer with a
00:40:07.202 --> 00:40:10.144
complex supply chain.>>
00:40:10.144 --> 00:40:12.425
Manuel Garza: So for security, does an
00:40:12.425 --> 00:40:14.643
importer have to have full
00:40:14.643 --> 00:40:16.002
implementation of the Forced Labor
00:40:16.002 --> 00:40:20.595
requirement?>>
00:40:20.595 --> 00:40:26.586
Must an existing-- must an existing
00:40:26.586 --> 00:40:30.993
CTPAT have a full implementation, or a
00:40:30.993 --> 00:40:34.743
good start for a large importer with a
00:40:34.743 --> 00:40:36.245
large supply chain.>>
00:40:36.245 --> 00:40:39.325
Manuel Garza: Again it should be based
00:40:39.325 --> 00:40:41.317
on risk that they should be focused on.
00:40:41.317 --> 00:40:45.527
And if risk means 100% for the company,
00:40:45.527 --> 00:40:49.492
then yes, it needs to be 100%. If risk
00:40:49.492 --> 00:40:53.028
is 20% for the company, it should be 20%
00:40:53.028 --> 00:40:55.205
risk that they identify.>>
00:40:55.205 --> 00:40:58.482
And do I only update the six requirements
00:40:58.482 --> 00:41:01.350
or do I have to resubmit the entire
00:41:01.350 --> 00:41:02.569
security profile?>>
00:41:02.569 --> 00:41:06.536
Manuel Garza: So I any they're
00:41:06.536 --> 00:41:09.836
confused. The six requirements are for
00:41:09.836 --> 00:41:11.616
the trade compliance partners. And they
00:41:11.616 --> 00:41:15.327
will get that. Six requirements are not
00:41:15.327 --> 00:41:19.540
for the CTPAT security. CTPAT security,
00:41:19.540 --> 00:41:21.971
there's just one criteria that has
00:41:21.971 --> 00:41:27.583
changed from a should to a must.>>
00:41:27.583 --> 00:41:33.454
Okay. Could you please clarify detained
00:41:33.454 --> 00:41:37.939
shipment or detained only when bonded
00:41:37.939 --> 00:41:39.698
warehouse or this is where I thought you
00:41:39.698 --> 00:41:44.606
were going something to FT. A's
00:41:44.606 --> 00:41:47.418
conditional release, too.>>
00:41:47.418 --> 00:41:50.128
Manuel Garza: I'm not sure I understand
00:41:50.128 --> 00:41:51.889
the complete question here.>>
00:41:51.889 --> 00:41:55.656
Let me-- can you please clarify-- for
00:41:55.656 --> 00:41:58.897
detained shipments, are they detained
00:41:58.897 --> 00:42:04.608
only, detain only going to the bonded
00:42:04.608 --> 00:42:06.703
warehouse or something to similar to
00:42:06.703 --> 00:42:09.696
what conditional, what's going on with
00:42:09.696 --> 00:42:15.153
FDA-- *.>>
00:42:15.153 --> 00:42:18.994
Manuel Garza: No. These are only--
00:42:18.994 --> 00:42:22.178
[Speakers Overlapping] no, this is only
00:42:22.178 --> 00:42:31.904
on the WRO shipments at this time.>>
00:42:31.904 --> 00:42:35.050
For current CTPAT member, we have the
00:42:35.050 --> 00:42:36.822
Forced Labor requirements in place,
00:42:36.822 --> 00:42:41.342
should we update our portal now or wait
00:42:41.342 --> 00:42:44.316
until August 2023?>>
00:42:44.316 --> 00:42:46.309
If you have them already, by all means,
00:42:46.309 --> 00:42:48.769
feel free to update them.>>
00:42:48.769 --> 00:42:55.027
Okay. We're trying-- what constitutes
00:42:55.027 --> 00:43:02.560
due diligence to validate suppliers?
00:43:02.560 --> 00:43:06.060
a supplier's sub supplier are compliant
00:43:06.060 --> 00:43:08.367
and how often must this level of audit
00:43:08.367 --> 00:43:10.446
be performed?>>
00:43:10.446 --> 00:43:13.267
Manuel Garza: Yeah, again, it's based
00:43:13.267 --> 00:43:15.262
on risk. So as you identify your risk
00:43:15.262 --> 00:43:17.917
are, whether it's your tier one
00:43:17.917 --> 00:43:22.315
supplier, tier two, tier three, those
00:43:22.315 --> 00:43:24.721
are what you need to identify as a
00:43:24.721 --> 00:43:27.369
business partner, risk. What Forced
00:43:27.369 --> 00:43:31.081
Labor doesn't stop at the first tier.
00:43:31.081 --> 00:43:33.174
Forced labor continues on. * so
00:43:33.174 --> 00:43:36.026
identifying, you know, okay, this sector
00:43:36.026 --> 00:43:39.764
within the supply chain, maybe you don't
00:43:39.764 --> 00:43:41.861
need to worry about a certain part that
00:43:41.861 --> 00:43:45.950
you have. But maybe there's another
00:43:45.950 --> 00:43:47.599
thing that you should be concerned
00:43:47.599 --> 00:43:48.385
about.So
00:43:48.385 --> 00:43:51.229
that's all about identifying risk. And,
00:43:51.229 --> 00:43:58.493
uh, and that's the extent, I think, that
00:43:58.493 --> 00:44:00.834
you should be going. Do I think
00:44:00.834 --> 00:44:04.781
anybody's going to be able to do 100% of
00:44:04.781 --> 00:44:07.086
their supply chain from scratch? I
00:44:07.086 --> 00:44:12.357
don't think so. But we want you guys to
00:44:12.357 --> 00:44:17.603
focus on your risk.>>
00:44:17.603 --> 00:44:23.871
I'm sorry. So staying on the topic of
00:44:23.871 --> 00:44:26.837
risk, we have another question that is
00:44:26.837 --> 00:44:30.482
from a freight forwarder. All these
00:44:30.482 --> 00:44:33.357
questions seem directed to be importers
00:44:33.357 --> 00:44:36.790
as a CTPAT freight forwarder, do you
00:44:36.790 --> 00:44:40.939
have practical suggestions to require
00:44:40.939 --> 00:44:42.909
with the requirements>>
00:44:42.909 --> 00:44:49.896
Unless you're acting as an importer,
00:44:49.896 --> 00:44:52.764
these are not applicable to you.>>
00:44:52.764 --> 00:44:55.950
And that was moves on, we got questions
00:44:55.950 --> 00:44:58.356
regarding, we did get another question
00:44:58.356 --> 00:45:00.672
that asks, if we are a security member
00:45:00.672 --> 00:45:03.217
and cannot many a trade compliance
00:45:03.217 --> 00:45:05.996
member, will our detention reviews also
00:45:05.996 --> 00:45:08.204
be given some sort of priority?>>
00:45:08.204 --> 00:45:10.605
Manuel Garza currently right now * the
00:45:10.605 --> 00:45:13.040
trade compliance partners are the ones
00:45:13.040 --> 00:45:15.475
receiving the benefit.>>
00:45:15.475 --> 00:45:24.209
Let's see. There's some questions. We
00:45:24.209 --> 00:45:25.901
have quite a few questions on Forced
00:45:25.901 --> 00:45:28.893
Laborment we're going to hold off on
00:45:28.893 --> 00:45:32.945
those until-- comes by to handle
00:45:32.945 --> 00:45:33.917
those.We
00:45:33.917 --> 00:45:35.785
did get a couple of questions, going
00:45:35.785 --> 00:45:38.319
back to the basics of what the
00:45:38.319 --> 00:45:40.786
difference is with a trade compliance
00:45:40.786 --> 00:45:42.963
and the security partner just in the
00:45:42.963 --> 00:45:46.395
beginning of the presentation.>>
00:45:46.395 --> 00:45:48.370
Manuel Garza: I'll start with security.
00:45:48.370 --> 00:45:52.877
CTPAT security we have 13 different
00:45:52.877 --> 00:45:56.299
entities that a are currently able to
00:45:56.299 --> 00:45:59.960
apply to the CTPAT program. Customs
00:45:59.960 --> 00:46:03.201
brokers, freight forwarders, air
00:46:03.201 --> 00:46:06.199
carriers, rail carriers, highway
00:46:06.199 --> 00:46:10.159
carriers, long all carriers, U.S.
00:46:10.159 --> 00:46:12.931
importers, exporters, et cetera. Those
00:46:12.931 --> 00:46:14.685
are the current security partners in the
00:46:14.685 --> 00:46:19.114
program.For
00:46:19.114 --> 00:46:22.704
importers, exporters, and the
00:46:22.704 --> 00:46:25.473
manufacturers, 9 for manufacturers
00:46:25.473 --> 00:46:28.882
located currently-- we only have
00:46:28.882 --> 00:46:31.093
manufacturers in Mexico and Canada.
00:46:31.093 --> 00:46:34.586
Those are * all required under the
00:46:34.586 --> 00:46:37.925
security criteria 3.9 that was recently
00:46:37.925 --> 00:46:42.208
changed from a should to a must. Those
00:46:42.208 --> 00:46:45.634
partners must have a social compliance
00:46:45.634 --> 00:46:51.839
policy in place that's security
00:46:51.839 --> 00:46:53.620
side.Trade
00:46:53.620 --> 00:46:57.900
compliance is an additional tier or an
00:46:57.900 --> 00:47:01.515
additional program within CTPAT. And it
00:47:01.515 --> 00:47:04.666
is only for importers.It's
00:47:04.666 --> 00:47:10.595
formally called the importer's
00:47:10.595 --> 00:47:13.215
self-assessment program, ISA. It's been
00:47:13.215 --> 00:47:16.738
moved under the CTPAT program. And it
00:47:16.738 --> 00:47:20.356
is now our CTPAT trade compliance
00:47:20.356 --> 00:47:28.047
program. With the trade compliance, the
00:47:28.047 --> 00:47:30.565
partner is responsible for submitting an
00:47:30.565 --> 00:47:35.214
annual review to CBP.On
00:47:35.214 --> 00:47:37.835
the security side, we do them every four
00:47:37.835 --> 00:47:39.732
years, and the supply chain specialist
00:47:39.732 --> 00:47:43.013
is the one who goes out and conducts a
00:47:43.013 --> 00:47:45.352
validation visit. Trade compliance,
00:47:45.352 --> 00:47:48.198
like I said, they submit their
00:47:48.198 --> 00:47:50.215
documentation after they did their own
00:47:50.215 --> 00:47:52.307
review, their own audit of their
00:47:52.307 --> 00:47:54.883
company. And this is for compliance
00:47:54.883 --> 00:47:58.303
related to entries and imports.They
00:47:58.303 --> 00:48:02.325
do their audit. And our national
00:48:02.325 --> 00:48:06.528
account managers, our import specialist
00:48:06.528 --> 00:48:10.500
whys review the documented submitted *
00:48:10.500 --> 00:48:15.431
and it comes to our Headquarters, trade
00:48:15.431 --> 00:48:18.204
compliance, whereby we do the final of
00:48:18.204 --> 00:48:20.726
those letters. Those are about the two
00:48:20.726 --> 00:48:24.561
differences in the programs.>>
00:48:24.561 --> 00:48:28.096
Thank you. I'm sorry. I believe that--
00:48:28.096 --> 00:48:30.779
[Speakers Overlapping].>>
00:48:30.779 --> 00:48:38.264
Special advisorrer now to CBP is on.
00:48:38.264 --> 00:48:40.708
I'm going to go back to the question from
00:48:40.708 --> 00:48:44.666
the beginning regarding today's CSMS
00:48:44.666 --> 00:48:49.843
message regarding if CBP updates amid--
00:48:49.843 --> 00:48:53.062
postal code that is subject to the labor
00:48:53.062 --> 00:48:56.116
pores, labor prevention act, how will
00:48:56.116 --> 00:49:00.395
the I am porter be notified to the
00:49:00.395 --> 00:49:03.535
postal code other than the WRO?>>
00:49:03.535 --> 00:49:05.128
Can you say that again?>>
00:49:05.128 --> 00:49:06.999
Okay. I'm sorry. [Speakers
00:49:06.999 --> 00:49:07.786
Overlapping]>>
00:49:07.786 --> 00:49:12.056
Would you like to introduce yourself
00:49:12.056 --> 00:49:13.775
first before I ask the question?>>
00:49:13.775 --> 00:49:16.550
I'm happy, too. I'm having an issue with
00:49:16.550 --> 00:49:24.081
video here. A here we go. Yeah, hi,
00:49:24.081 --> 00:49:27.189
everybody I'm Theresa. I'm special
00:49:27.189 --> 00:49:33.590
advisor to the Forced Labor division in
00:49:33.590 --> 00:49:36.449
the office of headquarters.>>
00:49:36.449 --> 00:49:41.244
This one it was regarding a CSMS message.
00:49:41.244 --> 00:49:48.309
If CBP updates amid versus CMSMS
00:49:48.309 --> 00:49:51.388
message including a postal code-- how
00:49:51.388 --> 00:49:55.401
would the importer be notified of the
00:49:55.401 --> 00:49:57.966
change through the postal code other
00:49:57.966 --> 00:50:01.658
than the WRO?>>
00:50:01.658 --> 00:50:04.054
the question, there's no WRO involved
00:50:04.054 --> 00:50:08.896
here because the postal code is under--
00:50:08.896 --> 00:50:12.637
shipments coming from the region of
00:50:12.637 --> 00:50:15.937
China and subject to the labor labor
00:50:15.937 --> 00:50:18.596
prevention act. There's no WRO involved
00:50:18.596 --> 00:50:19.869
here.the
00:50:19.869 --> 00:50:24.834
in terms of the notification to the
00:50:24.834 --> 00:50:27.362
importer that a postal code has been
00:50:27.362 --> 00:50:29.669
changed-- I will have to get back to you
00:50:29.669 --> 00:50:32.249
on that because I have not been closely
00:50:32.249 --> 00:50:35.689
involved in the development of the
00:50:35.689 --> 00:50:40.931
postal code, how that's going to work.I
00:50:40.931 --> 00:50:43.205
know there's a lot of position on the
00:50:43.205 --> 00:50:45.101
trade support network related to that.
00:50:45.101 --> 00:50:48.097
But I have to take that question back.>>
00:50:48.097 --> 00:50:54.683
Okay. If the company's going through
00:50:54.683 --> 00:50:58.514
risk and analysis survey assessment, how
00:50:58.514 --> 00:51:04.317
will they be grandfathered into CTPAT
00:51:04.317 --> 00:51:06.098
compliance? Maybe that's not for you.
00:51:06.098 --> 00:51:08.938
But for Manny, sorry.>>
00:51:08.938 --> 00:51:11.902
Manuel Garza: Can you repeat the
00:51:11.902 --> 00:51:12.993
question, please>>
00:51:12.993 --> 00:51:17.364
If a company is going through a RASA,
00:51:17.364 --> 00:51:20.889
will they be grandfathered into CTPAT
00:51:20.889 --> 00:51:23.009
compliance?>>
00:51:23.009 --> 00:51:24.443
I don't know what they mean by
00:51:24.443 --> 00:51:26.350
grandfathered in. They will still be
00:51:26.350 --> 00:51:28.468
required. If they applied and going
00:51:28.468 --> 00:51:31.838
through the process, then I don't
00:51:31.838 --> 00:51:34.178
believe that they would have had to
00:51:34.178 --> 00:51:37.926
submit their documentation because that
00:51:37.926 --> 00:51:39.829
might have been ongoing for sometime
00:51:39.829 --> 00:51:41.507
now.I
00:51:41.507 --> 00:51:43.345
don't believe any of the new applicants
00:51:43.345 --> 00:51:47.314
are going to RASOs right now. * but at
00:51:47.314 --> 00:51:50.937
the time, once they're certified, trade
00:51:50.937 --> 00:51:53.902
compliance, for their next cycle, they
00:51:53.902 --> 00:51:56.856
will be required to provide the
00:51:56.856 --> 00:51:59.762
information on the six requirements.>>
00:51:59.762 --> 00:52:02.315
I will say, I'm sorry to interrupt.
00:52:02.315 --> 00:52:05.381
There was, and I don't know if the
00:52:05.381 --> 00:52:08.711
confusion might be-- there's a
00:52:08.711 --> 00:52:11.670
historical benefit on a focused
00:52:11.670 --> 00:52:14.399
assessment into the trade compliance
00:52:14.399 --> 00:52:18.727
program, formerly importer assessment
00:52:18.727 --> 00:52:19.576
program.We
00:52:19.576 --> 00:52:22.506
have not yet gotten rid of that benefit.
00:52:22.506 --> 00:52:26.465
Of so the focus assessment or focus
00:52:26.465 --> 00:52:29.993
assessment into trade compliance. So
00:52:29.993 --> 00:52:32.991
that could be maybe a little bit of the
00:52:32.991 --> 00:52:36.417
confusion also. So that's still around
00:52:36.417 --> 00:52:39.792
per right now in case that's what
00:52:39.792 --> 00:52:41.881
somebody may be thinking.>>
00:52:41.881 --> 00:53:00.373
Okay, I'm looking for more Ms.
00:53:00.373 --> 00:53:04.584
Radazzo.When
00:53:04.584 --> 00:53:10.593
will the postal code application be
00:53:10.593 --> 00:53:11.259
enforced?>>
00:53:11.259 --> 00:53:18.217
It starts on March.>>
00:53:18.217 --> 00:53:25.366
Randazzo * *>>
00:53:25.366 --> 00:53:32.807
Will there be a list provided of the--
00:53:32.807 --> 00:53:35.020
[inaudible]. Is that what's going to
00:53:35.020 --> 00:53:38.873
be-- post al code affected.>>
00:53:38.873 --> 00:53:42.586
In all of this, all of the postal codes
00:53:42.586 --> 00:53:46.548
are covered-- it will be covered.
00:53:46.548 --> 00:53:49.107
There's not going to be change to them.
00:53:49.107 --> 00:53:51.071
There's not a list of them specifically.
00:53:51.071 --> 00:53:53.164
It's all of them.>>
00:53:53.164 --> 00:53:59.740
Okay. I don't see any more-- Kate, do
00:53:59.740 --> 00:54:02.899
you see any more?>>
00:54:02.899 --> 00:54:06.267
Related to that, I did want to go back,
00:54:06.267 --> 00:54:08.049
a couple of questions regarding the
00:54:08.049 --> 00:54:13.678
benefits for WRO in detention. We
00:54:13.678 --> 00:54:15.983
announced the benefits back in November.
00:54:15.983 --> 00:54:19.516
And we've been getting questions about
00:54:19.516 --> 00:54:22.445
the, one of the questions was, can we
00:54:22.445 --> 00:54:29.605
clarify whether the movement of goods
00:54:29.605 --> 00:54:33.424
for bonds-- if it's just for WRO, can
00:54:33.424 --> 00:54:36.077
you advise whether the other benefits
00:54:36.077 --> 00:54:38.711
for trade compliance is also limited to
00:54:38.711 --> 00:54:42.009
WRO? There's been confusion, I think,
00:54:42.009 --> 00:54:43.624
regarding the benefits.>>
00:54:43.624 --> 00:54:49.615
Manuel Garza: I think I had already
00:54:49.615 --> 00:54:54.247
clarified that particular one.
00:54:54.247 --> 00:54:59.635
Currently it's for WRO only. We are
00:54:59.635 --> 00:55:03.252
still evaluating whether it will be
00:55:03.252 --> 00:55:06.746
implemented for that.>>
00:55:06.746 --> 00:55:12.367
Okay, here's another one for Theresa.
00:55:12.367 --> 00:55:16.074
When will the importer be notified that
00:55:16.074 --> 00:55:22.226
had the shipment will be detained for
00:55:22.226 --> 00:55:26.280
use postal code in the ISF documentation
00:55:26.280 --> 00:55:27.812
filing?>>
00:55:27.812 --> 00:55:35.265
So the notification would be at entry.
00:55:35.265 --> 00:55:38.914
At-- the postal code requirements is part
00:55:38.914 --> 00:55:41.788
of release. So you will be notified at
00:55:41.788 --> 00:55:44.564
that time that there's, the postal code
00:55:44.564 --> 00:55:48.633
goes back to location in the-- and if
00:55:48.633 --> 00:55:51.675
you decide to enter the goods anyway,
00:55:51.675 --> 00:55:56.515
then they will all be detained because--
00:55:56.515 --> 00:56:00.035
are excluded immediately because it's
00:56:00.035 --> 00:56:02.907
subject to immediate exclusion.>>
00:56:02.907 --> 00:56:11.124
Where is the list of the subject postal
00:56:11.124 --> 00:56:12.430
code?>>
00:56:12.430 --> 00:56:16.242
It's all in the post at code in the zing
00:56:16.242 --> 00:56:21.220
Giang. *>>
00:56:21.220 --> 00:56:23.065
I don't believe I have any more for you.
00:56:23.065 --> 00:56:25.968
Was there anything else that I
00:56:25.968 --> 00:56:26.684
missed?>>
00:56:26.684 --> 00:56:28.650
I think we're running into our last
00:56:28.650 --> 00:56:31.175
couple of minutes. We did have one
00:56:31.175 --> 00:56:34.703
question regarding Forced Labor's, how
00:56:34.703 --> 00:56:37.587
are I am shoulds selected for compliance
00:56:37.587 --> 00:56:41.646
for Forced Labor? That mighting a broad
00:56:41.646 --> 00:56:43.174
question and we're getting tight on
00:56:43.174 --> 00:56:45.015
time, I think.>>
00:56:45.015 --> 00:56:51.553
So is this a general question about how
00:56:51.553 --> 00:56:54.846
we select shipments for-->>
00:56:54.846 --> 00:56:55.807
Yes, ma'am.>>
00:56:55.807 --> 00:57:01.271
For-- for potential forced labor
00:57:01.271 --> 00:57:04.351
concerns? And so we select shipments
00:57:04.351 --> 00:57:07.476
based on the intelligence and
00:57:07.476 --> 00:57:09.548
information that we have available. We
00:57:09.548 --> 00:57:11.664
work to identify the highest risk
00:57:11.664 --> 00:57:13.666
shipments based on the available
00:57:13.666 --> 00:57:15.001
information.And
00:57:15.001 --> 00:57:17.435
then those shipments are targeted. I
00:57:17.435 --> 00:57:20.176
guess that's the short form answer I can
00:57:20.176 --> 00:57:31.787
give with limited time here.>>
00:57:31.787 --> 00:57:34.202
Thank you. I think that's it. I mean,
00:57:34.202 --> 00:57:36.857
we have one minute left, if there's any
00:57:36.857 --> 00:57:39.534
other questions or comments coming in,
00:57:39.534 --> 00:57:50.414
please put them in the CHAT box.>>
00:57:50.414 --> 00:57:52.580
Thank you, everyone. This concludes our
00:57:52.580 --> 00:57:55.078
webinar for this afternoon. Please keep
00:57:55.078 --> 00:57:58.850
in mind that registration will be coming
00:57:58.850 --> 00:58:05.899
out soon for the trade facilitation,
00:58:05.899 --> 00:58:08.083
April 17 through 19. Thank you for

00:58:10.503 --> 00:58:10.503
your day.>>